People v. Valderama

Defendant was charged with multiple counts of sexual assault and sexual abuse. Appellant, a rape counseling center, appealed from a trial court order finding it in indirect civil contempt for refusing to respond to the defendant’s subpoena requesting records related to the counseling of the alleged victim. The appellate court reversed, finding that the trial court order calling for an in camera inspection of the counseling records was a clear abuse of discretion where there was no evidence that the confidential statements contained in the record would provide a source of impeaching material that was unavailable from other sources. (HUTCHINSON and MULLEN, concurring)